Antioxidant Superiority Award
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Antioxidant Superiority Award Version 2: September 2019 Clean Label Project Code of Practice: Antioxidant Superiority September 2019 The Clean Label Project is a national non-profit with the mission to bring truth and transparency to consumer product labeling. Using actual retail sampling and testing, we establish evidence-based benchmarks to identify the America’s best products using data and science as opposed to marketing. Together, we are changing the definition of food and consumer product safety in America. 1 | Page Copyright © 2019 by Clean Label Project All rights reserved. Clean Label Project Code of Practice: Antioxidant Superiority September 2019 This Code of Practice: Antioxidant Superiority Award is subject to revision. Go to www.cleanlabelproject.org to confirm the current version. Questions, clarification, interpretations, and suggested revisions regarding this Code of Practice: Antioxidant Superiority Award may be provided in writing to: Clean Label Project 280 E. 1st Ave. #873 Broomfield, CO 80038-0873 E-mail: [email protected] 2 | Page Copyright © 2019 by Clean Label Project All rights reserved. Clean Label Project Code of Practice: Antioxidant Superiority September 2019 Date of Publication: September 2019 Published by: Clean Label Project 280 E. 1st Ave. #873 Broomfield, CO 80038-0873 Copyright © 2019 by Clean Label Project All rights reserved. 3 | Page Copyright © 2019 by Clean Label Project All rights reserved. Clean Label Project Code of Practice: Antioxidant Superiority September 2019 Objectives and Disclaimers This Code of Practice provides criteria for the evaluation and marketing of manufacturers seeking compliance and certification for their products to the Clean Label Project Code of Practice- Antioxidant Superiority. The implied compliance, evaluations, and the contents contained within are limited exclusively to meeting the minimum requirements for the Clean Label Project Code of Practice - Antioxidant Superiority. It is the responsibility of the Operator to comply with all applicable state, national, and international laws such as, but not limited to, California Prop 65, FDA food labeling laws, FDA food safety laws, FDA pesticide tolerance level requirements, Country of Origin labeling, Tobacco, Tax, and Trade Bureau Laws, and USDA National Organic Program requirements, as applicable. It is also the responsibility of the Operator to comply with any applicable voluntary third-party private schemes such as, but not limited to Organic, Fair Trade, and Global Food Safety Initiative benchmarked standards. In no way does compliance to this Clean Label Project Code of Practice- Antioxidant Superiority imply compliance to any other state or federal regulation or private standard. The Clean Label Project does not assume, displace, or undertake to discharge any obligations or responsibilities of the manufacturer or any other party, including but not limited to those responsibilities and obligations arising from the other certifications or standards referenced within this Clean Label Project Code of Practice- Antioxidant Superiority. Under no circumstances shall Clean Label Project or any of its affiliates be liable for direct, indirect, incidental, consequential, special, punitive or any other use of this Clean Label Project Code of Practice- Antioxidant Superiority. This Clean Label Project Code of Practice- Antioxidant Superiority may be revised from time to time. Use of this Clean Label Project Code of Practice- Antioxidant Superiority is strictly voluntary. 4 | Page Copyright © 2019 by Clean Label Project All rights reserved. Clean Label Project Code of Practice: Antioxidant Superiority September 2019 © Clean Label Project Version 2 Code of Practice- Antioxidant Superiority I. Purpose Antioxidants come up frequently in conversations about good health. Typically found in fresh fruits and vegetables, antioxidants are known to help prevent free-radical formation. Free- radicals can form naturally in the body during the process of turning food into energy1. We are also exposed to free-radicals regularly in our daily contact with known toxins and contaminants. It is for this reason that antioxidants are important to Clean Label Project and our mission to reduce industrial and environmental contaminants and toxins in food and consumer products. The Clean Label Project Code of Practice: Antioxidant Superiority looks to create a program that encourages the use of ingredients and processes that result in finished products with higher levels of antioxidants and antioxidant activity. Given Clean Label Project’s mission to reduce exposure to industrial and environmental contaminants, Clean Label Project wants to reward Operators using ingredients and methodologies that maximize the presence of antioxidants and their beneficial attributes. The purpose of the Code of Practice is to: 1. Provide a market tool and evaluation criteria for growers, suppliers, manufacturers, brand owners, and retailers to begin identifying, evaluating, and maximizing antioxidants within their products 2. Create a market opportunity for manufacturers looking to communicate this commitment to consumers 3. Satisfy the growing consumer demand for transparency through an on-package market solution that is backed by testing and data 4. Get back to the basics and provide consumers assurance and trust by looking beyond the flashy marketing because sometimes what’s not on the label is the most important 5. Create a standard with antioxidant sampling and testing requirements Note: In an effort to minimize Operators that intend on only committing to negligible higher levels of antioxidants or antioxidant activity, any Operator seeking Clean Label Project: Antioxidant Superiority shall have a minimum of 10% over the category average as identified by the methodology and benchmarked products (see Appendices for more information). II. Scope Growers, manufacturers, co-manufacturers, brand owners, and retailers are eligible to apply for the Clean Label Project Code of Practice- Antioxidant Superiority Award. This Code of Practice- Antioxidant Superiority outlines compliance documentation and marketing requirements and guidelines. 5 | Page Copyright © 2019 by Clean Label Project All rights reserved. Clean Label Project Code of Practice: Antioxidant Superiority September 2019 III. Limitations The contents of this document require producing documentation demonstrating compliance to certain minimum applicable food safety standards. This Code of Practice does not constitute a guarantee of 100% of products are compliant to the stated limits. There is inherent variability in consumer-packaged goods batches, loads, and runs. However, QA programs that adhere to “best practices” should deliver high levels of consistency. There is a certain percent error that is assumed using analytical chemistry instrumentation at low detection levels. These shall be accounted for during the compliance evaluation process. IV. References 1 https://www.hsph.harvard.edu/nutritionsource/antioxidants/ V. Definitions A. Administrator: the organization(s) contractually responsible for the Clean Label Project Code of Practice- Antioxidant Superiority implementation and oversight B. Awarded: An Operator that has been formally recognized by the Administrator as fulfilling the requirements as outlined in the Clean Label Project Code of Practice- Antioxidant Superiority C. Non-Compliant: Nonconformance to established requirements within the Clean Label Project Code of Practice- Antioxidant Superiority D. Operator: the organization, business, entity, or person(s) responsible for Clean Label Project- Antioxidant Superiority compliance oversight E. Superiority: results found to be in the top 33% of the representative sample set VI. Compliance Framework A. Initial Compliance Requirements 1. Proof of Food Safety/Good Manufacturing Practices (GMP) Compliance Food safety and/or good manufacturing audits are now a normal and necessary component within the food and consumer product supply chain. An Operator shall provide proof of food safety or GMP compliance. Examples of food safety compliance include, but are not limited to, proof of certification under a Global Food Safety Initiative benchmarked standard or proof of compliance to other third-party specified food safety or GMP standards. 6 | Page Copyright © 2019 by Clean Label Project All rights reserved. Clean Label Project Code of Practice: Antioxidant Superiority September 2019 Standards such as USDA National Organic Program, Kosher, or another food quality/marketing standard shall not be deemed sufficient. Proof of Food Safety/GMP Compliance documentation shall be dated within the past 18 months. The location listed on the Proof of Food Safety Compliance documentation shall match the location of product manufacture disclosed on application documentation. If an Operator uses multiple co-packers or co- manufacturers, proof of food safety shall be supplied for each location. 2. Representative Sample Justification The foundation of the Clean Label Project Code of Practice: Antioxidant Superiority is that an Operator’s commitment to using ingredients and processes that result in higher levels of antioxidants and antioxidant activity is superior to that of the product category. Clean Label Project and its Technical Administrator shall work with the Operator to identify a mutually agreeable representative sample set in which to assess superiority. This shall be facilitated on a case by case basis. The results of the representative sample